; Date: Tue Sep 06 2022
Signing up with a mail forwarding or virtual mailbox service requires filling out USPS form 1583. While the form looks to be simple, there are many details that can trip you up.
USPS Form 1583 ( https://about.usps.com/forms/ps1583.pdf) allows postal mail to be handled by a mail delivery agent. The technical name for these agents is Commercial Mail Receiving Agency (CMRA). The businesses are certified by the US Postal Service (USPS) to allow postal service employees to deliver mail to the service on behalf of its customers. CMRA's have certain requirements to fulfill in order to stay in good graces with the US Postal Service.
The key requirement to get service from a CMRA is to file a USPS form 1583 documenting a permanent home address. While this form is relatively simple, there are some details that cause some confusion. We found the documentation published by the CMRA's to be almost worthless, missing important details. However, some of the CMRA's we spoke with provided some helpful advice, from which we were able to put two-and-two together to better understand the requirements.
Examples of CMRA's are:
- Virtual Mailbox providers, which are physical locations where mail can be delivered, and your mail address is a box number at that location. These providers scan the outside of the package, and send you a notification, and can provide a number of services including scanning the content, discarding (or shredding) the mail, or forwarding it to another location.
- Mail Forwarding Service is similar to a virtual mailbox provider, but in some states there is a key legal distinction allowing the address from a mail forwarding service to be used as a home address for a drivers license.
- Shipping services focus on receiving packages, and sending them to a recipient address. For example a non-US person may want to order an item from a US retailer that does not ship to their home country. The shipping service can receive that package at a US address, then send it to them in their home country.
The common feature is that the CMRA is receiving and handling mail on behalf of the CMRA customer.
The result is that a service with a physical location at 123 Main Street in Anytown, MA, USA, can provide you with a mailing address like this:
Josephine Brown 123 Main Street, #1123 ---OR--- PMB 1123 Anytown, MA USA #####-####
The USPS documentation says the preferred address form is to use
PMB NNNN, where PMB means Private Mailbox. This is technically different from a POB, or Post Office Box. The form
#NNNN is documented by the USPS as an alternate. We also know from experience that
Suite NNNN or
STE NNNN is also allowed.
The purpose for a virtual mailbox is so you can receive mail other than at your residence. This is useful for folks who travel a lot, or for folks who worry about the safety of mail delivered to their home. The virtual mailbox service will receive your physical mail, notify you of the mail, scan the envelope, and offer other services including forwarding/shipping the mail to another address.
The key requirement for a successful form 1583 submitted to a CMRA (virtual mailbox service) is to supply identity documents that validate the physical address you claim in box 7 of the form.
Box 7 is where one puts their home address. In other words, form 1583 documents that the CMRA customer living at a given home address (box 7) wants to receive mail at an address provided by the CMRA (box 3).
The box 7 home address can be an old address. You might move around frequently and only have an ID card on an old address. The CMRA's we spoke with said that was okay in terms of being a legitimate form 1583 submission. To understand why that is, we must look carefully at both the form and the USPS rules.
Getting back to Form 1583... the USPS requires that CMRA's receive a notarized copy of form 1583. This form describes the person setting up the virtual mailbox, along with their home address and the identity documents provided for proof. The result is a degree of certainty that the CMRA customer is who they say they are.
In part this form serves to assist enforcing certain laws, such as money laundering laws. Keep this in mind as we go through the form.
The form looks deceptively simple. That's what we thought when applying for virtual mailbox service, but it took a lot of study to precisely understand the form.
- Box 2 is simply your name.
- Boxes 3a, 3b, 3c, etc, identify the mailing address offered by your virtual mailbox service.
- Boxes 4a, 4b, etc, identify the CMRA, a.k.a. virtual mailbox, from whom you are renting service.
- Box 5 you'll probably just enter YES
- Box 6 has you repeat your name for some reason
- Boxes 7a, 7b, etc, is your home address.
- Box 8 lists the identity documents you show to the CMRA
- Boxes 9, 10, 11, etc is important if this mailbox is for a business
These look straight-forward enough, right? Most people have a home address, and have ID cards like a drivers license etc.
But, what happens for people who legitimately do not have a home address? Some people have work which keeps them traveling 100% of the time, or they are traveling in an RV full time, or otherwise do not maintain a permanent home address. Virtual mailbox services are perfect for such people, but how are they to fill in box 7 to show their home address?
We discussed that question with the customer support team at a couple CMRA's. We learned from them that the box 7 address can be an "old address". What's required is that you have a legitimate ID card which demonstrates the address in box 7. One CMRA support person said even if the address was from five addresses ago, you can use an ID card on that address for USPS form 1583.
We were told that the box 7 home address can be a foreign (non-US address) validated by a foreign (non-US) ID card. However, form 1583 box 7 only supports a US address, and the list of acceptable identity documents do not include a foreign (non-US) ID card. It does allow a foreign passport, but since passports do not include addresses it cannot be used to validate the box 7 address.
The key is that the post office needs to see an identity document with an address that matching box 7 in the supplied form 1583.
To understand this better let's look also at box 8. We're told to supply two forms of identification, with these instructions:
- Two types of identification are required. One must contain a photograph of the addressee(s). Social Security cards, credit cards, and birth certificates are unacceptable as identification. The agent must write in identifying information. Subject to verification.
- Acceptable identification includes: valid driver's license or state non-driver's identification card; armed forces, government, university, or recognized corporate identification card; passport, alien registration card or certificate of naturalization; current lease, mortgage or Deed of Trust; voter or vehicle registration card; or a home or vehicle insurance policy. A photocopy of your identification may be retained by agent for verification.
While this seems clear it leaves out some very important details. For example it does not discuss the requirement that the identification have a matching physical address. Customer service at the CMRA's we consulted clearly said the identity documents had to validate the address shown in box 7. The question is, what does that mean precisely?
On a FAQ page ( https://faq.usps.com/s/article/Acceptable-Form-of-Identification) the USPS breaks down the list of acceptable forms of identification into two groups, Primary forms of photo identification, and Secondary forms of identification. The first group must be a photo ID, such as a US Government ID, drivers license, passport, a corporate ID card, or a university ID card. The second group includes mortgages, leases, votor registration, and the like.
While discussing the second group of identity documents, this is said:
An acceptable secondary form of identification, traceable to the bearer, is required to verify the validity of the address provided when you apply or request certain products and services.
In other words, part of the goal of this exercise is to verify the validity of the address provided in box 7. One of the acceptable identity documents must validate that address.
That page also links to the Domestic Mail Manual, which seems to be the rulebook for USPS operations. The manual goes into more detail than what is published in the USPS FAQ. In the Federal Register, in May 2019, an update to this manual shows changes made to update rules on identity documents. That change resulted in a tightening of policies at CMRA's.
For example, a person might have a US passport, a foreign passport and a Citizen Naturalization document. Each of those are photo ID's, and clearly document that the person exists, and is a US citizen. But none of them have an address, and therefore do not validate the address in box 7.
In our case there was an old voter registration for a previous address. The registrar of voters in each state (or county) in the US typically has a website where you can look up your voter registration. It was sufficient to go on that website, pull up the registration, then print a screen capture of the browser window demonstrating the URL of the site showing the registration data.
Who determines if a form 1583 is legitimate?
The CMRA (a.k.a. virtual address provider) determines if their customer has submitted a valid form 1583. CMRA's are supposed to reject the form if the physical address in box 7 cannot be substantiated by an identity document.
The USPS does receive a copy of each form 1583. But, it does not verify the addresses shown on the 1583 unless there is reason to believe that unlawful activity is being conducted through the mailbox.
Does the CMRA have leeway to accept other ID forms?
It appears that a CMRA is allowed to accept other ID forms.
The instructions posted by America's Mailbox (a CMRA offering Mail Forwarding service in South Dakota) says this about box 7 of form 1583:
- Your most current physical address, or the most current address where you receive mail, goes here.
- This cannot be a PO Box.
- If you live in your vehicle, indicate that and list the state where it is registered and the license plate number.
America's Mailbox is specifically geared to folks living full time in an RV, who are travling from here to there to somewhere else. Such people do not have a home address. Hence, America's Mailbox allows folks to list their RV as their home address.
This clearly does not match with the requirements in the USPS Domestic Mail Manual.
As we note below, the CMRA determines if the 1583 is legitimate. The CMRA supplies the form 1583 to the Postmaster, who sticks it into a filing cabinet without verifying the addresses. This means the CMRA can accept a 1583 and be satisfied with the addresses without facing review by the USPS. But one wonders what would happen if the USPS has need to investigate a form 1583 where the CMRA accepted such an address?
How many form 1583's are required?
One form 1583 is required for each individual application to the CMRA service. For example a family might apply for a mailbox. Each family member must submit a separate form 1583 to the CMRA, each with their own identity documents.
Are we required to notify the CMRA of updates?
If information supplied on form 1583 changes, we are required to notify the CMRA. We do this by generating a new form 1583 and write on the form the word "REVISED". ID documents must be supplied with the revised form 1583.
What requirements do Commercial Mail Receiving Agencies have to the USPS?
The Domestic Mail Manual in sections 508.1.8.1 through 508.1.8.4 goes into great detail into the operation of a CMRA.
To start a CMRA, the CMRA operator submits a form 1583-A ( Application to Act as a Commercial Mail Receiving Agency) to the USPS. This form simply lists the address of the CMRA operator, and has them swear to abide by the requirements.
The CMRA keeps all submitted 1583's on file, and must make them available for inspection by postal inspectors at any time. Quarterly, the CMRA must submit a report to the USPS listing all mailbox's it is currently operating. This list will show new accounts, long-term accounts, and any accounts that were canceled in the last 6 months.
The CMRA supplies the original copy of each submitted 1583 to the "postmaster" (the postal service). The postmaster keeps those on file, but does not verify the addresses on the form. If, however, the Postal Inspector requests address verification, or there is reason to believe the address is being used for unlawful purposes, the postmaster will attempt to verify the addresses.
The CMRA keeps a duplicate of the form 1583's in its own files.
Bottom line is that USPS form 1583 requires a home address in box 7, and that in box 8 the applicant supply an identity document that validates the home address.
For form 1583 box 8, two identity documents must be supplied. At least one must have a photo, and at least one must validate the box 7 home address.